Finnish Supreme Administrative Court Rules on Interquartile Range in Transfer Pricing Adjustment

The Finnish Supreme Administrative Court issued a decision on 13 September 2021 regarding the appropriate value to be used in the interquartile range for a transfer pricing adjustment. The case involved the Finnish parent company of a group that had failed to appropriately charge royalties to its foreign subsidiaries for the use of the company's intangible assets, which resulted in a transfer pricing adjustment for the uncollected royalties.

The company agreed with the tax administration o…